Free Motion to Continue Trial - District Court of Arizona - Arizona

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

ANN E M . W ILL IAM S, P.C. ANNE M . WILLIAMS # 012414 amw illiams@ cox.net Attorney at Law 1833 East Baseline Road - PMB 265 Gilbert, Arizona 85233-1545 (T) 480.892.7177 (F) 480.471.6652 Attorney for Charles Tyrone Harris

IN THE UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA

United States of America, 2:04-cr-01058-002-PHX-FJM Plaintiff, v. MOTION TO CONTINUE TRIAL AND EXTEND TIME TO FILE PRETRIAL MOTIONS AND PROPOSED FORM OF ORDER (Third Request) Defendant.

CHARLES TYRONE HARRIS,

Charles Tyrone Harris, through undersigned counsel, moves this Court to continue the trial date of May 2, 2006, for an additional sixty (60) days. Mr. Harris requests additional time for investigation, to explore alternative resolution of the case and/or prepare for trial. Mr. Harris further requests this Court extend the time to file pretrial motions for an additional forty-five (45) days from the current date. Assistant U.S. Attorney, Kurt Altman, has been contacted regarding this motion and has no objection to the requested continuance. All other defendants are pending sentencing or have been sentenced. Therefore, this request does not involve their matters. ///

Case 2:04-cr-01058-FJM

Document 83

Filed 03/21/2006

Page 1 of 2

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

It is expected that excludable delay under Title 18 U.S.C. Section 3161(h)(1)(F) may occur as a result of this motion or from an order based thereon.

Respectfully submitted: March 21, 2006.

/S/ ANNE M. WILLIAMS ANNE M. WILLIAMS, P.C.

Copy of the foregoing served this date via transmittal of Notice of Electronic Filing to CM /ECF reg istrant(s): Mr. Kurt Altman [email protected] As sistan t U.S. Attorney M s. An ne M. W illia m s amw illiams@ cox.net Counsel for Mr. Harris Courtesy copy with pro posed order pro vided via e-mail attachment to: Honorable Frederick J. Martone [email protected]

2

Case 2:04-cr-01058-FJM

Document 83

Filed 03/21/2006

Page 2 of 2